The CIR Approval Timetable: Two Windows You Cannot Miss

Approval under France’s research tax credit (crédit d’impôt recherche, CIR) is one of the rare French schemes where the filing date matters as much as the content of the file. An excellent application lodged on 2 April will have no effect for the current year. A thoroughly deserved approval whose renewal was forgotten between 15 August and 30 November leaves the provider uncovered on the following 1 January — with invoices its clients cannot claim.

There is nothing obscure about this timetable, but it is poorly publicised and often discovered too late. Here it is, with its practical consequences.

The two CIR approval campaigns

Approval is assessed in whole calendar years. It cannot be applied for at any time: the ministry responsible for research opens two distinct campaigns.

Situation	Filing window	Effect
First application	1 January to 31 March of the year applied for	Covers the year applied for
Renewal	15 August to 30 November of the last year granted	Continuity with no interruption

Outside those windows, approval only takes effect from the following year. That is a dead loss for the current year’s clients, and it cannot be recovered.

For approval applied for under the innovation tax credit alone, the logic is the same but the date changes: the reference is 30 September of the year applied for, for both a first application and a renewal. Our comparison of CIR and CII approval sets out which of the two procedures applies to you.

Where to file

Filing is done online. The ministry responsible for research has modernised its procedure around the CIROCO application, which centralises the filing of applications, the transmission of supporting documents and exchanges with the administration. Standalone CII applications go through the online procedure accessible from the pages the Directorate General for Enterprise devotes to the scheme.

Two practical consequences of that digitalisation. First, the filing window is technically closed outside the campaign: there is no paper fallback, and no few-days tolerance. Second, exchanges with the assessing expert go through the platform: someone internally has to check it regularly, otherwise a request for further information may go unanswered until the deadline expires.

The duration granted is not always the one you expect

Many directors assume approval means three years. That is the default case, but not the only rule.

• Three years is the standard duration for approval under the research tax credit.
• One year, where the organisation or expert has carried out no research operation in the twelve months before the application. That is the typical case of a young company seeking approval before it has a track record, or of an organisation whose research activity has been interrupted.
• Five years, possible for organisations or experts approved continuously over a long period and having carried out a research operation in the twelve months before the application. It rewards regularity and is reserved for established players.

Approval granted under the innovation tax credit alone covers five years.

The consequence matters for a young company: a first one-year approval means filing again the very next year, in the August–November window. Many are unaware of this, file the decision away, and discover the deadline in January.

The real risk: a gap in coverage

Refusal is not the main threat. The threat is the coverage gap.

Approval expires on a date known to everyone from day one. If the renewal is not filed between 15 August and 30 November of the last year granted, the organisation finds itself unapproved on 1 January. It then has to wait for the first-application campaign in the first quarter — and in the meantime its invoices cannot be claimed by its clients.

Three knock-on effects, all unpleasant:

1. Your clients lose deductibility for work done during the interruption, with no possibility of retroactive correction.
2. You find out late, usually the following spring when the client prepares its return — months after the fact.
3. Trust erodes over an administrative matter that was entirely within your control, which is the hardest thing to explain.

Four habits are enough to eliminate the risk.

• Put the expiry date in the management diary, not just in an administrative folder, with an alert on 1 August.
• Name a specific person responsible for the file, plus a deputy. The subject is often orphaned between scientific and financial management.
• Keep a standing file all year: up-to-date CVs, the year’s list of research operations, publications, patents. Renewal is prepared continuously, not in November.
• Tell your clients about the renewal period and the expiry date, in your terms of business or your proposals. That turns a constraint into a signal of seriousness.

Why continuity matters economically

An interruption in approval does not just mean an unclaimable invoice: it changes the real cost of outsourced research for the client, and therefore the client’s trade-off. Irem Guceri and Li Liu published a quasi-experimental evaluation of R&D tax incentives in the American Economic Journal: Economic Policy in 2019, based on a threshold reform and estimated on the universe of corporation tax filings of one country. They estimate a user-cost elasticity of R&D spending well above one in absolute value — that is, a strong response by firms to changes in that cost (see the study).

Translated into a provider’s language: when your approval lapses, the net cost of your work rises mechanically for your client, and the purchasing decision follows. It is not an administrative formality that stops, it is your price competitiveness.

Building your reverse timetable

Here is the sequence to install once and for all in the company calendar.

For a first application:

• September to December: assembling the file — human resources, material resources, descriptions of research operations, dissemination. See our guide on what the ministry looks at.
• First half of January: filing. Aiming at the start of the window leaves the margin you need if a document is missing.
• January to summer: assessment, answers to requests for further information, notification of the decision.

For a renewal:

• 1 August: automatic alert, a fifteen-minute meeting to check that the standing file is up to date.
• Second half of August: filing, as soon as the window opens.
• September to November: safety margin in case of a technical difficulty or a request for documents.

The general principle fits in one sentence: never aim at the end of a window. A file lodged on 30 March or 29 November cannot be corrected if it is incomplete.

Take action

Open your approval decision and put three dates in the management diary: the expiry date, 1 August of the last year covered, and the 15 August that follows. If you are not yet approved, the only question that matters is whether your file will be ready on 1 January — because the window closes on 31 March, and no invoice issued in the meantime can be recovered. The full mechanism is explained in our article on subcontracted research and approval, and the detailed scheme status, with the free ebook, is on our page dedicated to CIR-CII approval.